Reg D: 3 or 6 for ACH check

In reviewing the latest batch of our suspected Reg D violations, I came across a client who has ACH items that include a check number. Our system recognizes these as checks (part of the 3 allowable in a statement cycle) but they're also tagged as ACH, which would lead me to shuffle them in to the 6 allowable transactions. For documentary purposes, and for notifying the client, how would you classify these debits?

Thanks in advance for your help!

I would classify them as checks. They probably started out as checks and then were converted into ACH's. The customer would probably recognize them as checks that they had written.

If the Fed staff is looking at our Threads, maybe they will get their proposed Reg. D changes implemented???? That would make the question moot.